--- title: DCAA Timekeeping Lore description: Guidance for labor recording can be found in DCAAM 7641.90 under Labor Charging System. If guidance is written in the DCAA's Information for Contractors manual, then it must be rooted in the regulations, correct? It might surprise you to learn the answer to this supposition is false. image: https://sql.sympaq.com/hubfs/ScaleMoneyTime.jpg --- [Contact: 800-437-8151](tel:18004378151) [Help Desk](https://aldebaron.assist.com/portal) [![DCAA Compliant Accounting System | SYMPAQ](https://sql.sympaq.com/hubfs/crop-trans-logo.png "Government Contract Cost Accounting")Project Cost Accounting Software for Government Contractors](https://www.sympaq.com/) - [PRODUCTS](https://www.sympaq.com/) - [SYMPAQ Accounting](https://www.sympaq.com/sympaq-sql/) - [SYMPAQ Time & Expense](https://www.sympaq.com/sympaq-etx/) - [SYMPAQ DEMOS](https://www.sympaq.com/demos/) - [PRICING](https://www.sympaq.com/sympaq-pricing/) - [SERVICES](https://www.sympaq.com/services/) - [AUDITS](https://www.sympaq.com/dcaa-audits/) - [DCAA Audits](https://www.sympaq.com/dcaa-audits/) - [Single Audits](https://www.sympaq.com/a-133-audits/) - [RESOURCES](https://www.sympaq.com/#) - [Events / Webinars](https://www.sympaq.com/events-schedule/) - [SYMPAQ Demos](https://www.sympaq.com/demos/) - [Useful Links](https://www.sympaq.com/useful-links/) - [BLOG](https://sql.sympaq.com/blog) [![REQUEST DEMO](https://no-cache.hubspot.com/cta/default/2695973/fa292e59-f01d-4acf-b907-53fc989efa07.png)](https://cta-redirect.hubspot.com/cta/redirect/2695973/fa292e59-f01d-4acf-b907-53fc989efa07) [![DCAA Compliant Accounting System | SYMPAQ](https://sql.sympaq.com/hubfs/crop-trans-logo.png "Government Contract Cost Accounting")Project Cost Accounting Software for Government Contractors](https://www.sympaq.com/) - [PRODUCTS](https://www.sympaq.com/) - [SYMPAQ Accounting](https://www.sympaq.com/sympaq-sql/) - [SYMPAQ Time & Expense](https://www.sympaq.com/sympaq-etx/) - [SYMPAQ DEMOS](https://www.sympaq.com/demos/) - [PRICING](https://www.sympaq.com/sympaq-pricing/) - [SERVICES](https://www.sympaq.com/services/) - [AUDITS](https://www.sympaq.com/dcaa-audits/) - [DCAA Audits](https://www.sympaq.com/dcaa-audits/) - [Single Audits](https://www.sympaq.com/a-133-audits/) - [RESOURCES](https://www.sympaq.com/#) - [Events / Webinars](https://www.sympaq.com/events-schedule/) - [SYMPAQ Demos](https://www.sympaq.com/demos/) - [Useful Links](https://www.sympaq.com/useful-links/) - [BLOG](https://sql.sympaq.com/blog) [![REQUEST DEMO](https://no-cache.hubspot.com/cta/default/2695973/fa292e59-f01d-4acf-b907-53fc989efa07.png)](https://cta-redirect.hubspot.com/cta/redirect/2695973/fa292e59-f01d-4acf-b907-53fc989efa07) [![DCAA Compliant Accounting System | SYMPAQ](https://sql.sympaq.com/hubfs/crop-trans-logo.png "Government Contract Cost Accounting")Project Cost Accounting Software for Government Contractors](https://www.sympaq.com/) menu close close - PRODUCTS - [SYMPAQ Accounting](https://www.sympaq.com/sympaq-sql/) - [SYMPAQ Time & Expense](https://www.sympaq.com/sympaq-etx/) - [SYMPAQ DEMOS](https://www.sympaq.com/demos/) - [PRICING](https://www.sympaq.com/sympaq-pricing/) - [SERVICES](https://www.sympaq.com/services/) - RESOURCES - [Events / Webinars](https://www.sympaq.com/events-schedule/) - [Useful Links](https://www.sympaq.com/useful-links/) - [BLOG](https://sql.sympaq.com/blog) ## Blog ### Subscribe to our Blog # DCAA Timekeeping Lore [Business Tips](https://sql.sympaq.com/blog/topic/business-tips), [DCAA](https://sql.sympaq.com/blog/topic/dcaa), [Accounting](https://sql.sympaq.com/blog/topic/accounting), [FAR Compliance](https://sql.sympaq.com/blog/topic/far-compliance) 05/24/2021 [G. Chris Brown](https://sql.sympaq.com/blog/author/cbrown) ![Scale balancing time and money](https://sql.sympaq.com/hs-fs/hubfs/ScaleMoneyTime.jpg?width=291&name=ScaleMoneyTime.jpg)Many moons ago, I was visiting with a client who told me that they had developed an electronic timekeeping system for their internal use. Things were going well until such time they received a surprise DCAA real-time labor evaluation also known as a "[floor check](https://www.dcaa.mil/Portals/88/Labor_Evaluations.pdf?ver=2019-10-15-162522-913)". When the auditor discovered that the software allowed a user the ability to charge time to a direct cost objective (i.e., contract) to days in the future, it was determined the labor charging system lacked a [key internal control](https://sql.sympaq.com/blog/your-internal-controls-speed-bumps-guardrails-and-stop-signs)and was deemed inadequate. The auditor's report recommended fixing the flaw of allowing future time charges to billable jobs or returning to paper timesheets. At the time of my visit, the CFO wondered how going back to paper timesheets would somehow prevent the entry of future time against a billable contract, not that they were guilty of authorizing such charges. When it comes to your employees and other team members filling out timesheets, we typically presume that the regulations from which the DCAA gets its authority to enforce timekeeping rules are embedded in the [Federal Acquisition Regulations](https://sql.sympaq.com/blog/rules-that-govern-inter-company-transactions)(FAR) and/or the Defense Acquisition Regulations Supplement (DFARS). Furthermore, as part of an onboarding process, employees joining the staff of a labor-intensive Federal Contractor soon learn about the compliance rules for recording direct and indirect labor charges. These procedures include filling out timesheets on a daily frequency, not allowing other staff members make time entries on another's behalf, accurately charging time to the correct job order number, and training for making corrections to previously recorded time entries. These practices and other related guidance surrounding labor recording can be found in DCAAM 7641.90 under Labor Charging System. So that's the final word, right? If guidance is written in the DCAA's Information for Contractors manual, then it must be rooted in the regulations (i.e., the FAR), correct? It might surprise you to learn the answer to this supposition is false. Related: [SYMPAQ eTX: DCAA-Compliant Time & Expense Solution](https://www.sympaq.com/sympaq-etx/) In searching through the voluminous FAR and DFARS, the words "timekeeping" and "timecard" are only referenced sporadically in a few "Parts". There is the [SF1408 criterion](https://sql.sympaq.com/blog/a-quick-guide-to-sf-1408), "A timekeeping system that identifies employees' labor by intermediate and final cost objectives" found in [DFARS](https://www.acquisition.gov/dfars/252.242-7006-accounting-system-administration)[252.42-7006](https://www.acquisition.gov/dfars/252.242-7006-accounting-system-administration). There is a reference to "individual daily job timekeeping records" in support of Payments under Time-and-Materials and Labor Hour Contracts (FAR 52.232.7). However, the "daily" relates to daily entries in support of a voucher, but nowhere does the regulation explicitly state that the time entries must be recorded on a daily frequency when working on a T&M contract. Since there is no time frequency specified, one can interpret this to mean there are no restrictions for waiting until the end of the workweek or labor period to record daily hours worked on the contract. While [FAR 31.205-2](https://sql.sympaq.com/blog/dcaa-far-31-205-cost-principals-guidebook) addresses record keeping in a broad sense in support of costs incurred, it does not specifically mention timekeeping or the need to complete timesheets daily or anything else that can be tied to the guidance set forth in DCAAM 7641.90. And "guidance" is the operative word as opposed to "regulation". Should an auditor raise concerns during the course of a floor check audit that a particular staff member has not completed his or her timesheet on a daily basis, you technically could ask the auditor to cite the regulation in support of enforcing time entries on a daily frequency. And what about the requirement to not allow for future time charges to billable contracts? While there is no direct reference to this contained in the FAR or in DCAAM 7641.90, there are plenty of references to fraud throughout the FAR. There is a catch-all paragraph under Labor Charging System in 7641.90 entitled Penalties for Labor Mischarging. To wit, "(1) The manipulation of charges to a contract may be subject to criminal charges under 18 United States Code (U.S.C.) 1001."  As the publisher of [SYMPAQ eTX for timekeeping](https://www.sympaq.com/sympaq-etx/), we take all guidance and regulations into account while developing a particular feature set or internal control. While it could be said that SYMPAQ is a "FAR compliant" cost accounting system, labor charging falls under the domain of DCAA compliance. To ensure compliance with the guidance, we've built in the business rules that remind staff members to complete their timesheets on a daily basis while preventing future time charges against direct contracts. While it can be argued that what isn't written in the FAR or DFARS doesn't hold water, adopting good common sense rules for timekeeping reduces labor mischarges and the potential for fraud. ![SYMPAQ 728X90 7.21](https://sql.sympaq.com/hs-fs/hubfs/SYMPAQ%20728X90%207.21.jpg?width=728&name=SYMPAQ%20728X90%207.21.jpg) ### Recent Blogs February, 07 2025 ## [Strong Headwinds Ahead for Federal Government Contractors in 2025](https://sql.sympaq.com/blog/5-challenges-federal-government-contracting-0) [Government Contractor](https://sql.sympaq.com/blog/topic/government-contractor) [Accounting Software](https://sql.sympaq.com/blog/topic/accounting-software) [SYMPAQ Benefits](https://sql.sympaq.com/blog/topic/sympaq-benefits) [Business Tips](https://sql.sympaq.com/blog/topic/business-tips) [Headwinds](https://sql.sympaq.com/blog/topic/headwinds) Poised to bid on contracts with the Federal Government? you will likely encounter challenges with procurement regulations and bureaucracy.[ Read the Blog](https://sql.sympaq.com/blog/5-challenges-federal-government-contracting-0) 0 Comments [Click here to read/write comments](https://sql.sympaq.com/blog/5-challenges-federal-government-contracting-0#comments-listing) January, 10 2025 ## [End of Year Tax Form Filing Has Never Been Easier!](https://sql.sympaq.com/blog/end-of-year-tax-form-filing-has-never-been-easier) [tax](https://sql.sympaq.com/blog/topic/tax) [2024](https://sql.sympaq.com/blog/topic/2024) As we learned last year when the paper filing threshold dropped from 250 for each tax form to 10 tax forms in aggregate (i.e., 1099-NEC plus 1099-Misc plus W2), one should no longer be contemplating t\[...\][ Read the Blog](https://sql.sympaq.com/blog/end-of-year-tax-form-filing-has-never-been-easier) 0 Comments [Click here to read/write comments](https://sql.sympaq.com/blog/end-of-year-tax-form-filing-has-never-been-easier#comments-listing) December, 04 2024 ## [Another Year, Another End-of-Year Update](https://sql.sympaq.com/blog/2024-year-end-of-year-update) [2024](https://sql.sympaq.com/blog/topic/2024) One thing we've learned over the years as a software publisher is that unless you are planning on sunsetting a legacy application, you are never "done" with development.[ Read the Blog](https://sql.sympaq.com/blog/2024-year-end-of-year-update) 0 Comments [Click here to read/write comments](https://sql.sympaq.com/blog/2024-year-end-of-year-update#comments-listing) ![](https://sql.sympaq.com/hs-fs/hubfs/crop-trans-logo.png?width=200&name=crop-trans-logo.png) We are focused on delivering reliable cost accounting, timekeeping and expense reporting solutions to labor-intensive federal government contractors and not-for-profit organizations in search of fully compliant, standards-based, project accounting software. ### Get In Touch [contact@sympaq.com](mailto:contact@sympaq.com) Local phone:[(301) 670-0858](tel:3016700858) Fax: (301) 840-1591 15839 Crabbs Branch Way, Rockville, MD 20855. [Privacy Policy](https://www.sympaq.com/privacy-policy/) [Cookie Policy](https://www.sympaq.com/cookie-policy/) [Terms & Conditions](https://www.sympaq.com/terms-and-conditions/) ### Subscribe to Our Blog Get the latest business resources on the market delivered to your inbox. Copyright © 2023 Aldebaron, Inc. All rights reserved. Website by [IMGdigitalAgency.com](https://www.imgdigitalagency.com/) [![](https://sql.sympaq.com/hubfs/blue-seal-bbb.png)](https://www.bbb.org/us/md/rockville/profile/computer-software-developers/sympaq-0241-236013238#sealclick) ![](https://px.ads.linkedin.com/collect/?pid=1997524&fmt=gif) × ### Speak to a Specialist Find out how SYMPAQ makes DCAA compliance a breeze. Fill out the form below to speak with a SYMPAQ team member. ```json { "@context" : "https://schema.org", "@type" : "BlogPosting", "author" : { "@type" : "Person", "name" : "G. Chris Brown", "url" : "https://sql.sympaq.com/blog/author/cbrown" }, "dateModified" : "2021-08-16T22:04:30.241Z", "datePublished" : "2021-05-24T14:59:40.000Z", "headline" : "DCAA Timekeeping Lore", "image" : [ "https://sql.sympaq.com/hubfs/ScaleMoneyTime.jpg" ], "mainEntityOfPage" : { "@id" : "https://sql.sympaq.com/blog/dcaa-timekeeping-lore", "@type" : "WebPage" }, "publisher" : { "@type" : "Organization", "logo" : { "@type" : "ImageObject", "url" : "https://sql.sympaq.com/hubfs/logo-2.png" }, "name" : "Aldebaron, Inc." } } ``` ```json { "@context" : "http://schema.org", "@type" : "BlogPosting", "author" : { "@type" : "Person", "name" : "G. Chris Brown" }, "dateModified" : "August 16, 2021, 10:04:30 PM", "datePublished" : "2021-05-24 14:59:40", "description" : "Guidance for labor recording can be found in DCAAM 7641.90 under Labor Charging System. If guidance is written in the DCAA's Information for Contractors manual, then it must be rooted in the regulations, correct? It might surprise you to learn the answer to this supposition is false.", "headline" : "DCAA Timekeeping Lore", "image" : { "@type" : "ImageObject", "url" : "https://sql.sympaq.com/hubfs/ScaleMoneyTime.jpg" }, "mainEntityOfPage" : { "@id" : "https://sql.sympaq.com/blog/dcaa-timekeeping-lore", "@type" : "WebPage" }, "publisher" : { "@type" : "Organization", "logo" : { "@type" : "ImageObject", "url" : "http://sql.sympaq.com/hubfs/sympaqlogo.png" }, "name" : "SYMPAQ" } } ```